CFPB issues 2020 annual complaint report

On March 24, 2021 the CFPB published its annual report summarizing the kinds of complaints consumers made throughout the prior year. The report is generally divided into two broad categories – complaints that relate to COVID-19 issues, and complaints that are part of trends that predate the pandemic. These compliant reports can be useful to review for a couple of reasons. One, the CFPB indicated its intent to take enforcement action against those entities that are not compliant with COVID-19 related guidance and requirements such as those stemming from the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). Two, complaints can sometimes inform where possible problems or concerns may lie. The bureau has historically used consumer complaints, as well as supervisory and enforcement trends, to inform future rulemaking efforts. Given the change in leadership at the CFPB and the expectation of moving to a more regulatory environment, sometimes these reports can hint towards future priorities.

The CFPB received about 542,300 consumer complaints in 2020 – significantly more than the 352,400 received in 2019 and 329,800 in 2018. The majority of the complaints last year related to credit or consumer reporting (59%), followed by debt collection (15%), credit cards (7%), deposit accounts (6%) and mortgages (5%).

In terms of consumer reporting, this year’s total complaints represented a 107% increase as compared to 2019. While the bureau attributes some of this increase to COVID-19 related issues, the upward trend in FCRA complaints predates the pandemic. However, most complaints in 2020 related to inaccurate information in reports supplied by the three largest Nationwide Credit Reporting Agencies (NCRAs) – Experian, Equifax, and TransUnion – and many related to identity theft issues.  Many complaints were specifically about the NCRAs – over 246,00 or 44% of the total complaints received (leaving only 15% of the year’s FCRA complaints about entities other than the NCRAs). The FCRA requires the bureau to issue an annual report specific to complaints about NCRAs. While this complaint report is typically the way the CFPB meets this requirement, given the number of complaints for 2020 specific to the NCRAs, the bureau will release a separate report later in 2021 to provide “a more robust analysis” of the NCRA-specific consumer complaints. One topic the CFPB flagged that may be relevant, were reports that some consumers’ credit scores dropped after entering a forbearance plan as well as reports that mortgages were reported as impacted by COVID-19 despite the borrowers being in good standing.


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